UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIALS AND APPEAL BOARD
`
`SL CORPORATION
`Petitioner,
`
`v.
`
`ADAPTIVE HEADLAMP TECHNOLOGIES, INC.
`Patent Owner
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,241,034
`Case IPR No.: Unassigned
`
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 7,241,034 UNDER 35 U.S.C. §§ 311-319 AND
`37 C.F.R. §§ 42.1-80, 42.100 et seq.
`
`DECLARATION OF HARVEY WEINBERG
`
`

`
`Table of Contents
`
`I.
`
`II.
`
`INTRODUCTION ...........................................................................................1
`
`BACKGROUND AND QUALIFICATIONS.................................................1
`
`III. MATERIALS CONSIDERED........................................................................2
`
`IV.
`
`V.
`
`VI.
`
`PERSON OF ORDINARY SKILL IN THE ART ..........................................3
`
`BACKGROUND OF TECHNOLOGY ..........................................................4
`
`SUMMARY OF THE ‘034 PATENT.............................................................5
`
`VII. CLAIM CONSTRUCTION ............................................................................5
`
`VIII. LEGAL STANDARD .....................................................................................6
`
`A.
`
`B.
`
`Anticipation...........................................................................................6
`
`Obviousness...........................................................................................7
`
`IX. ANALYSIS OF THE ‘034 PATENT CLAIMS..............................................8
`
`A.
`
`Claims 7-9, 13-18, 21-24, and 28-33 are anticipated by Kato..............8
`
`Claims 3-6, and 10-12 would have been obvious over Kato in view of
`B.
`Izawa and in view of the Patent Owner’s admission in the specification that
`condition sensors of the invention are “conventional.”.................................23
`
`To the extent the “predetermined minimum threshold” limitation of
`C.
`Claims 3 and 7 is not inherently present in Kato, it would have been obvious
`over Kato in view of Takahashi.....................................................................30
`
`Claims 19 and 20 would have been obvious over Kato and the Patent
`D.
`Owner’s admission in the specification that the actuators of the invention are
`“conventional.” ..............................................................................................32
`
`Claims 25-27 would have been obvious over Kato in view of the
`E.
`patent owner’s admission that feedback sensors are “conventional.”...........34
`
`Claims 33-35 would have been obvious over Kato in view of
`F.
`Takahashi.......................................................................................................36
`
`i
`
`

`
`G.
`
`H.
`
`Claims 36-39 would have been obvious over Kato in view of Hayami.
`.............................................................................................................39
`
`Claims 7-9, 13-17, 21-24, and 28-33 are anticipated by Fukuwa.......45
`
`Claims 3-6, and 10-12 would have been obvious over Fukuwa in view
`I.
`of Izawa and in view of the Patent Owner’s admission in the specification
`that condition sensors of the invention are “conventional.”..........................60
`
`To the extent the “predetermined minimum threshold” limitation of
`J.
`Claims 3 and 7 is not inherently present in Fukuwa, it would have been
`obvious over Fukuwa in view of Takahashi..................................................67
`
`Claims 18-20 would have been obvious over Fukuwa and the Patent
`K.
`Owner’s admission in the specification that the actuators of the invention are
`“conventional.” ..............................................................................................69
`
`Claims 25-27 would have been obvious over Fukuwa in view of the
`L.
`patent owner’s admission that feedback sensors are “conventional.”...........71
`
`Claims 33-35 would have been obvious over Fukuwa in view of
`M.
`Takahashi.......................................................................................................74
`
`Claims 36-39 would have been obvious over Fukuwa in view of
`N.
`Hayami...........................................................................................................76
`
`X.
`
`SECONDARY CONSIDERATIONS...........................................................82
`
`ii
`
`

`
`I, Harvey Weinberg, being of legal age, hereby declare, affirm, and state the
`
`following:
`
`I.
`
`1.
`
`INTRODUCTION
`
`I have been retained on behalf of Petitioner, SL Corporation (“SL”), to offer
`
`statements and opinions generally regarding the validity, novelty, prior art,
`
`obviousness considerations, and understanding of a person of ordinary skill in the
`
`art (“POSITA”) in the industry as it relates to U.S. Patent No. 7,241,034 (“’034
`
`patent”). Attached hereto as Appendix A is a true and correct copy of my
`
`Curriculum Vitae describing my background and experience. I have personal
`
`knowledge of the facts and opinions set forth in this declaration, and, if called upon
`
`to do so, I would testify competently thereto. All of the opinions and conclusions
`
`found in this declaration are my own.
`
`2.
`
`I am being compensated at a rate of $200 per hour for my services. This
`
`compensation is in no way based on the content of my opinions or the outcome of
`
`this matter.
`
`II.
`
`3.
`
`4.
`
`BACKGROUND AND QUALIFICATIONS
`
`Please refer to my resume attached as Appendix A.
`
`To summarize with respect to the technology of the ‘034 patent, I have over
`
`18 years of experience in the automotive industry in various areas supporting
`
`automotive OEMs directly and through Tier-One manufacturers in the following
`
`1
`
`

`
`applications: MEMS inertial sensors used for crash detection (sensors used in
`
`center crash modules as well as those used as “satellite” sensors at doors, near front
`
`bumpers, etc.); MEMS inertial sensors (gyroscopes and low-g accelerometers)
`
`used in electronic stability control; MEMS inertial sensors (gyroscopes and
`
`accelerometers) used in roll over detection; MEMS inertial sensors (gyroscopes
`
`and accelerometers) used in body/chassis management electronics including theft
`
`alarms, sliding door protection, noise cancellation, suspension control, etc.; current
`
`sensing for transmission control; Li-Ion and Lead-Acid battery management for
`
`conventional internal combustion engines as well as hybrid electric vehicles; and
`
`LIDAR (optical RADAR) systems for short and mid-range presence detection.
`
`III. MATERIALS CONSIDERED
`
`5.
`
`In developing my opinions below relating to the ‘034 patent, I have
`
`considered the materials cited herein, as well as the following materials:
`
`6.
`
`7.
`
`8.
`
`9.
`
`US Patent 7,241,034 (“the ’034 Patent”) (Petition Ex. 1001);
`
`Japanese Patent Application No. 09-151649 (“Kato”) (Petition Ex. 1023);
`
`Japanese Patent Application No. 10-364667 (“Fukuwa”) (Petition Ex. 1024);
`
`UK Patent Application GB2,309,774 (“Takahashi) (Petition Ex. 1018);
`
`10. US Patent 6,293,686 (“Hayami”) (Petition Ex. 1025);
`
`11. ROBERT BOSCH GMBH, AUTOMOTIVE HANDBOOK (Horst Bauer et al. eds.,
`
`5th ed. 2000) (Appendix B);
`
`2
`
`

`
`12.
`
`PAUL HOROWITZ & WINFIELD HILL, THE ART OF ELECTRONICS (Cambridge
`
`University Press, 1981) (Appendix C).
`
`IV. PERSON OF ORDINARY SKILL IN THE ART
`
`13.
`
`The opinions offered in this Declaration are offered from the perspective of
`
`one of ordinary skill in the art as of October 31, 2000.
`
`14.
`
`I have been informed and understand that a POSITA is a hypothetical person
`
`who is presumed to have known all of the relevant art at the time of the invention.
`
`I have been informed and understand that, in determining the level of skill in the
`
`art, one may consider: the type of problems encountered in the art, prior art
`
`solutions to those problems, the rapidity with which innovations are made, the
`
`sophistication of the technology, and the educational level of active workers in the
`
`field.
`
`15.
`
`In my opinion, a POSITA at the time of the alleged inventions claimed by
`
`the ‘034 patent, would have had a minimum of an undergraduate degree in
`
`Mechanical or Electrical Engineering, Engineering Physics, or a comparable field,
`
`or equivalent industry experience. In addition, a POSITA would have had two or
`
`more years of professional automotive industry experience.
`
`16.
`
`I understand that a POSITA is presumed to have knowledge of all relevant
`
`prior art. Therefore, a POSITA would have been familiar with each of the prior art
`
`references cited herein and the full range of teachings they contain.
`
`3
`
`

`
`V.
`
`17.
`
`BACKGROUND OF TECHNOLOGY
`
`The concept of directional control of headlights is quite old. Examples of
`
`vehicles with directionally controlled headlights include:
`
`" The 1935 Tatra 77a (which included a third center headlight loosely linked to
`
`the steering wheel);
`
`" The 1948 Tucker 48 (which also included a third center headlight that was
`
`loosely linked to the steering wheel);
`
`" Non-US models of the 1967 Citroen DS (which incorporated headlights that
`
`swiveled up to 80 degrees left/right in response to steering wheel input);
`
`" The 1948 Citroen 2CV (which included a manual headlamp leveling system,
`
`controlled through a mechanical linkage); and
`
`" Vehicles incorporating an automatic headlamp leveling system introduced in
`
`1954 by Cibie (an automotive supplier specializing in lighting devices) that was
`
`linked to the vehicle's suspension system to keep the headlamps correctly
`
`aimed.
`
`18. As of the 1970s, Germany (and some other European countries) mandated
`
`remote-control headlamp leveling systems that permit the driver to lower the
`
`headlight aim by means of a dashboard control lever, or knob, in response to a
`
`heavily loaded rear of the car (which raises the headlight’s aim angle and creates
`
`glare for oncoming vehicles). Such systems typically use a motor at the headlamp
`
`4
`
`

`
`and a rotary switch on the dash. With the advent of high intensity headlight
`
`technology in the 1990s, multiple European car models have incorporated
`
`automatic leveling in response to legislation mandating headlight beam control,
`
`specifically ECE regulation 48.
`
`VI.
`
`19.
`
`SUMMARY OF THE ‘034 PATENT
`
`I have reviewed the ‘034 patent, entitled “Automatic Directional Control
`
`System for Vehicle Headlights,” which issued on July 10, 2007 to James E. Smith,
`
`et al and for which a Reexamination Certificate issued on June 14, 2013. The ‘034
`
`patent relates to a system for changing the direction in which the headlights of a
`
`vehicle are pointed in response to changes in the operating condition of the vehicle.
`
`The system includes, among other things, two sensors to detect pitch and steering
`
`angle, a controller responsive to these sensor signals, and actuators responsive to
`
`the controller to move the headlights in accordance with the signals received from
`
`the sensors.
`
`VII. CLAIM CONSTRUCTION
`I have been informed that for the purposes of this inter partes review, the
`
`20.
`
`standard for claim construction of terms within the claims of the patent is the
`
`“broadest reasonable construction” in light of the specification, which is different
`
`from the standard that applies in federal district court litigation.
`
`5
`
`

`
`21.
`
`For the purposes of this declaration, I have been asked to assume
`
`constructions for certain claim terms as presented below.
`
`22.
`
`Proposed constructions:
`
`1.
`
`2.
`
`3.
`
`predetermined minimum threshold amount : a preset signal
`value that must be exceeded before an action [operating the
`actuators] is taken.
`controller: any control system for selectively operating the
`actuators.
`configured to store a predetermined reference position:
`capable of storing a predetermined reference position.
`
`VIII. LEGAL STANDARD
`
`A.
`
`Anticipation
`
`23.
`
`I have been advised that if each and every element or step of a claim is
`
`disclosed within the “four corners” of a prior art reference, that claim is said to be
`
`“anticipated” by that single prior art reference and invalid under 35 U.S.C. § 102
`
`because the claim is not, in fact, new or novel.
`
`24.
`
`I have also been advised that a prior art reference can inherently disclose a
`
`claimed feature even if that feature is not expressly described by that reference. I
`
`understand that a feature is inherent in a prior art reference, if the feature not
`
`expressly described is necessarily present. I also understand that inherency cannot
`
`be established by probabilities or possibilities, and that the mere fact that
`
`something may result from a given set of circumstances is not sufficient to show
`
`inherency.
`
`6
`
`

`
`B.
`
`Obviousness
`
`25.
`
`I have been informed that a claim may be invalid under 35 U.S.C. § 103(a) if
`
`the subject matter described by the claim as a whole would have been obvious to a
`
`POSITA at the time the claimed invention was made.
`
`26.
`
`I have also been informed that a determination of obviousness involves an
`
`analysis of the scope and content of the prior art, the similarities between the
`
`claimed invention and the prior art, and the level of ordinary skill in the art. I have
`
`been informed and understand that a prior art reference should be viewed as a
`
`whole.
`
`27.
`
`I have been informed that in considering whether an invention for a claimed
`
`combination would have been obvious, I may assess whether there are apparent
`
`reasons to combine known elements in the prior art in the manner claimed in view
`
`of interrelated teachings of multiple prior art references, the effects of demands
`
`known to the design community or present in the market place, and/or the
`
`background knowledge possessed by a POSITA. I also understand that other
`
`principles may be relied on in evaluating whether a claimed invention would have
`
`been obvious.
`
`28.
`
`I have been told that, in making a determination as to whether or not the
`
`claimed invention would have been obvious to a POSITA, one may consider
`
`certain objective indicators of non-obviousness if they are present, such as:
`
`7
`
`

`
`commercial success of product(s) practicing the claimed invention; long-felt but
`
`unsolved need; teaching away; unexpected results; copying; and praise by others in
`
`the field. I understand that for such objective evidence to be relevant to the non-
`
`obviousness of a claim, there must be a causal relationship (called a “nexus”)
`
`between the claim and the evidence. I also understand that this nexus must be
`
`based on a novel element of the claim rather than something available in the prior
`
`art.
`
`29.
`
`I have also been informed and understand that when considering the
`
`obviousness of a patent claim, one should consider whether a reason or motivation
`
`existed for combining the elements of the references in the manner claimed, so as
`
`to avoid impermissibly applying hindsight.
`
`IX. ANALYSIS OF THE ‘034 PATENT CLAIMS
`
`30.
`
`I have concluded that each of the claims of the ‘034 patent identified below
`
`are invalid based on the references described below.
`
`A.
`
`Claims 7-9, 13-18, 21-24, and 28-33 are anticipated by Kato.
`
`31.
`
`I have been told that Kato is prior art to the ‘034 patent. I have reviewed the
`
`Kato reference. As set forth in more detail below, it is my opinion that Kato
`
`anticipates claims 7-9, 13-18, 21-24, and 28-33 of the ‘034 patent.
`
`1.
`
`Claim 7
`Limitation: An automatic directional control system for
`a vehicle headlight, comprising:
`
`a.
`
`8
`
`

`
`32.
`
`I have been informed that the preamble of patent claims does not always
`
`limit the claim’s scope. To the extent the preamble is considered to limit the claim,
`
`Kato discloses this limitation. For example, Kato discloses a motorcycle headlight
`
`directional control system that adjusts the aim of the headlight(s) in response to
`
`more than one sensor input. Kato at Claim 4. Therefore, Kato teaches an
`
`automatic directional control system for a vehicle headlight.
`
`b.
`
`Limitation: two or more sensors that are each adapted to
`generate a signal that is representative of at least one of a
`plurality of sensed conditions of a vehicle such that two
`or more sensor signals are generated, said sensed
`conditions including at least a steering angle and a pitch
`of the vehicle;
`
`33. Kato discloses this limitation. For example, Kato describes using a pitch
`
`angle sensor, a bank angle sensor, a speed sensor, and a steering angle sensor, all
`
`providing input to a controller that, using this information, controls an actuator to
`
`adjust the aim of the headlight(s) so as to maintain a desired light beam pattern on
`
`the road. Kato at Claim 4; id. at Fig. 1 (reproduced below).
`
`9
`
`

`
`Kato at Fig. 1.
`
`34. Kato explains that “[t]he steering angle sensor 16 is a rotary potentiometer
`
`4+$4 ’(4(&43 $ 34((2,/* $/*-( 83" ,#(#" $/ $/*-( 0) .$/,15-$4,0/ 0) 4+( +$/’-(%$2#6
`
`Kato at ¶ 17, id. at Fig. 1 & 2. A rotary potentiometer is a variable resistor whose
`
`resistance is proportional to the rotary position of the potentiometer’s rotatable
`
`shaft versus its body. As would be known by a POSITA, it is commonly used as a
`
`rotary position sensor.
`
`35. Kato also discloses a “pitch angle sensor” which detects “pitch angle.” Kato
`
`at ¶ 13. “The pitch angle sensor detects changes in the pitch angle due to tilting of
`
`the vehicle body.” Id. at ¶ 8. This sensor is comprised of two “rectilinear
`
`potentiometers” which “detect stroke length” at the front and rear wheels,
`
`respectively. Id. at ¶¶ 16-17. By measuring the respective height (or stroke) of the
`
`front and rear suspension the pitch angle of the vehicle can be measured. Id. at Fig.
`
`5.
`
`Kato at Fig. 5.
`
`10
`
`

`
`c.
`
`Limitation: a controller that is responsive to said two or
`more sensor signals for generating at least one output
`signal only when at least one of said two or more sensor
`signals changes by more than a predetermined minimum
`threshold amount to prevent at least one of two or more
`actuators from being operated continuously or unduly
`frequently in response to relatively small variations in at
`least one of the sensed conditions; and
`
`36. Kato discloses this limitation. For example, Kato discloses “controller 24”
`
`which is a “microcomputer with a built-in program for optical axis control.” Kato
`
`at ¶ 17. This controller is used to calculate the correction angle needed to adjust
`
`the headlight so as to maintain a desired light beam pattern on the road and this
`
`information is relayed to multiple actuators (step motors 22x, 22y, and 22z) that
`
`move the headlight to the necessary position. Id. at ¶¶ 13 and 16.
`
`37. Kato inherently discloses the use of a predetermined minimum threshold
`
`because the control system Kato describes actuates the headlight via the multiple
`
`step motors. Kato at ¶ 19. Unlike DC or servomotors, step motors, by virtue of
`
`their design, may only move in quantized steps (not continuously). See id. at ¶ 17
`
`(“The step motors … turn forward and backward by a predetermined angle in
`
`accordance with a pulse signal output.”). For example, a step motor designed to
`
`rotate in 5 degree increments can only rotate in 5 degree increments. Such a step
`
`motor could not rotate, for example, 2 degrees. As the step motor is incapable of
`
`moving in anything but quantized steps, the headlight controller cannot actuate
`
`angle changes continuously. Step motors move when they receive a pulse. Id. To
`
`11
`
`

`
`accommodate the quantized steps of the step motors, the controller of Kato must
`
`necessarily send a pulse to cause the step motor to adjust the headlight angle only
`
`when the amount of movement required meets or exceeds the rotation provided by
`
`a single angular step of the step motor, which is a predetermined minimum
`
`threshold. The effect of having such a threshold is to prevent the actuators from
`
`being operated continuously or unduly frequently in response to relatively small
`
`variations.
`
`d.
`
`Limitation: said two or more actuators each being
`adapted to be connected to the vehicle headlight to effect
`movement thereof in accordance with said at least one
`output signal;
`
`38. Kato discloses this limitation. For example, Kato discloses a front lamp
`
`optical control device comprised of several types of sensors, a controller that
`
`determines the amount of correction necessary, and an actuator to rotate the optical
`
`axis of a front lamp in response to one or more of these sensors. Kato at ¶¶ 7-9.
`
`e.
`
`Limitation: wherein said two or more sensors include a
`first sensor and a second sensor; and
`
`39. Kato discloses this limitation. For example, Kato discloses using two or
`
`more sensors as input to a controller that signals an actuator to control headlight
`
`position. Kato teaches the use of “a pitch angle sensor that detects a pitch angle, a
`
`steering angle sensor that detects a steering angle, [and] a vehicle speed sensor that
`
`12
`
`

`
`detects vehicle speed.” Kato at Claim 4. “The pitch angle sensor detects changes
`
`in the pitch angle due to tilting of the vehicle body.” Id. at ¶ 8.
`
`f.
`
`Limitation: wherein said first sensor is adapted to
`generate a signal that is representative of a condition
`including the steering angle of the vehicle and said
`second sensor is adapted to generate a signal that is
`representative of a condition including the pitch of the
`vehicle.
`
`40. Kato discloses this limitation. For example, Kato discloses a first sensor that
`
`generates a signal representative of steering angle and a second sensor
`
`representative of vehicle pitch. Specifically, Kato teaches using “a pitch angle
`
`sensor that detects a pitch angle, a steering angle sensor that detects a steering
`
`angle.” Kato at Claim 4.
`
`2.
`
`Claim 8
`Limitation: The automatic directional control system
`defined in claim 7, wherein said first sensor is physically
`separate from said second sensor.
`
`41. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 8. For example, Kato teaches the use
`
`of “a pitch angle sensor that detects a pitch angle, a bank angle sensor that detects a
`
`bank angle, a steering angle sensor that detects a steering angle, [and] a vehicle
`
`speed sensor that detects a vehicle speed.” Kato at Claim 4. Each of these sensors
`
`is physically separate as shown in Kato Figure 2. The pitch angle sensors are
`
`13
`
`

`
`located at the front and back of the vehicle, while the steering angle sensor is
`
`located near the handlebar. Id. at Fig. 2.
`
`3.
`
`Claim 9
`Limitation: The automatic directional control system
`defined in claim 7, further comprising one or more
`additional sensors for sensing one or more of a rate of
`change of road speed of the vehicle, a rate of change of
`the steering angle of the vehicle, a rate of change of the
`pitch of the vehicle, a suspension height of the vehicle, or
`a rate of change of suspension height of the vehicle.
`
`42. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 9. For example, Kato discloses that
`
`“[t]he potentiometers 121 and 122 are rectilinear potentiometers which are
`
`provided to suspension on a front wheel and a back wheel and detect stroke
`
`length.” Kato at ¶ 17. As discussed above in Paragraph 35, these potentiometers
`
`measure the suspension height of the vehicle.
`
`4.
`
`Claim 13
`Limitation: The automatic directional control system
`defined in claim 9, wherein at least one of said one or
`more additional sensors generate a signal that is
`representative of the suspension height of the vehicle.
`
`43. As discussed above, Kato discloses all of the elements of Claim 9. Kato also
`
`discloses the additional limitation of Claim 13. For example, Kato discloses that
`
`“[t]he potentiometers 121 and 122 are rectilinear potentiometers which are
`
`provided to suspension on a front wheel and a back wheel and detect stroke
`
`14
`
`

`
`length.” Kato at ¶ 17. As discussed above in Paragraph 35, these potentiometers
`
`measure the suspension height of the vehicle.
`
`5.
`
`Claim 14
`Limitation: The automatic directional control system
`defined in claim 7, wherein the automatic directional
`control system is configured such that said two or more
`actuators include a first actuator and a second actuator
`and wherein the first actuator connected to the headlight
`to effect movement thereof in a first direction and the
`second actuator connected to the headlight to effect
`movement thereof in a second direction different from
`the first direction.
`
`44. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 14. For example, Kato discloses the
`
`use of several step motors: “Specifically, the step motor 22x rotates the optical axis
`
`of the front lamp 20 in the bank angle direction Db around an X-axis. The step
`
`motor 22y rotates the optical axis of the front lamp 20 in the pitch angle direction
`
`Dp around a Y-axis. And the step motor 22z rotates the optical axis of the front
`
`lamp 20 in the steering angle direction Ds around a Z-axis.” Kato at ¶ 19. Each of
`
`the step motors “serve as the actuator” to moves the headlight in a distinct
`
`direction. Id. at ¶ 16.
`
`6.
`
`Claim 15
`Limitation: The automatic directional control system
`defined in claim 7, wherein the two or more actuators
`include a first actuator that is adapted to be connected to
`the headlight to effect movement thereof in a vertical
`direction.
`
`15
`
`

`
`45. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 15. For example, Kato discloses a
`
`“step motor 22x [that] rotates the optical axis of the front lamp 20 in the bank
`
`angle direction Db around an X-axis.” Kato at ¶ 19.
`
`7.
`
`Claim 16
`Limitation: The automatic directional control system
`defined in claim 15, wherein the two or more actuators
`include a second actuator that is adapted to be connected
`to the headlight to effect movement thereof in a
`horizontal direction.
`
`46. As discussed above, Kato discloses all of the elements of Claim 15. Kato
`
`also discloses the additional limitation of Claim 16. For example, Kato discloses a
`
`“step motor 22y [that] rotates the optical axis of the front lamp 20 in the bank
`
`angle direction Dp around an Y-axis.” Kato at ¶ 19.
`
`8.
`
`Claim 17
`Limitation: The automatic directional control system
`defined in claim 7, wherein the two or more actuators
`include an electronically controlled mechanical actuator.
`
`47. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 17. For example, Kato discloses that
`
`“[t]he step motors 22x, 22y, and 22z turn forward and backward by a
`
`predetermined angle in accordance with a pulse signal output by the controller 24.”
`
`Kato at ¶ 17. A step motor is an electronically controlled mechanical actuator.
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`16
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`9.
`
`Claim 18
`Limitation: The automatic directional control system
`defined in claim 7, wherein the two or more actuators
`include a step motor.
`
`48. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 18. For example, Kato discloses that
`
`“[t]he step motors 22x, 22y, and 22z turn forward and backward by a
`
`predetermined angle in accordance with a pulse signal output by the controller 24.”
`
`Kato at ¶ 17. The step motors “serve as an actuator.” Id. at ¶ 16.Thus, Kato
`
`teaches the use of a step motor.
`
`10. Claim 21
`Limitation: The automatic directional control system
`defined in claim 7, wherein the automatic directional
`control system is configured such that the headlight is
`adjustably mounted on the vehicle such that a directional
`orientation at which a beam of light projects therefrom is
`capable of being adjusted both up and down relative to a
`horizontal reference position and left and right relative to
`a vertical reference position.
`
`49. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 21. For example, Kato discloses the
`
`use of several step motors: “Specifically, the step motor 22x rotates the optical axis
`
`of the front lamp 20 in the bank angle direction Db around an X-axis. The step
`
`motor 22y rotates the optical axis of the front lamp 20 in the pitch angle direction
`
`Dp around a Y-axis. And the step motor 22z rotates the optical axis of the front
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`17
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`

`
`lamp 20 in the steering angle direction Ds around a Z-axis.” Kato at ¶ 19. The
`
`step motors move the headlight up and down relative to a horizontal axis, and left
`
`and right relative to a vertical axis.
`
`11. Claim 22
`Limitation: The automatic directional control system
`defined in claim 7, wherein the automatic directional
`control system is configured such that, while in a
`calibration mode, a directional orientation at which a
`beam of light projects is capable of being adjusted
`relative to the vehicle by manual operation of the two or
`more actuators.
`
`50. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 22. For example, Kato discloses a
`
`“three-dimensional map” stored in the controller which is used for calculating the
`
`necessary corrections. Kato at ¶ 30-31. This three-dimensional map is vehicle
`
`specific, and within it contains a sort of baseline or pre-calibrated state.
`
`51. Headlight and sensor placement not only differs from model to model due to
`
`design variations, but those variables also differ between vehicles of the same
`
`model due to small differences in manufacturing within the permitted tolerances.
`
`In addition, headlight and sensor alignment can change as a result of normal wear
`
`and tear. Due to the nature of headlights, a small difference in headlight position
`
`becomes a very large difference when the light is projected down the road. For
`
`this reason, some states require that headlight aim be checked as part of a vehicle’s
`
`18
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`

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`annual inspection. Likewise, a small difference in sensor position may become a
`
`big difference in sensed condition. There is no way to practically account for these
`
`alignment variations resulting from manufacturing tolerances or from normal wear
`
`and tear without manual calibration. Therefore, all headlight systems, including
`
`that of Kato, must inherently have a mechanism for calibrating the headlights by
`
`manual adjustment.
`
`12. Claim 23
`Limitation: 23. The automatic directional control system
`defined in claim 7, wherein the automatic directional
`control system is configured such that the controller
`includes a microprocessor.
`
`52. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 23. For example, Kato discloses that
`
`“controller 24 is a microcomputer with a built-in program for optical axis control.”
`
`Kato at ¶ 17. The terms microcomputer and microprocessor are used
`
`interchangeably in the art.
`
`13. Claim 24
`Limitation: The automatic directional control system
`defined in claim 7, wherein the automatic directional
`control system is configured such that the controller
`includes a programmable electronic controller.
`
`53. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`discloses the additional limitation of Claim 24. For example, Kato discloses that
`
`19
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`

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`“controller 24 is a microcomputer with a built-in program for optical axis control.”
`
`Kato at ¶ 17. A microcomputer is a programmable electronic controller.
`
`14. Claim 28
`Limitation: The automatic directional control system
`defined in claim 7, wherein the automatic directional
`control system further includes memory.
`
`54. As discussed above, Kato discloses all of the elements of Claim 7. Kato also
`
`inherently discloses the additional limitation of Claim 28. For example, Kato
`
`discloses that a “three-dimensional map is stored in the controller 24 ahead of
`
`time.” Kato at ¶ 31. Kato also discloses the use of a “built-in program.” Id. at ¶
`
`17. In order to store the map and the program, the controller must necessarily
`
`include a memory.
`
`15. Claim 29
`Limitation: The automatic directional control system
`defined in claim 28, wherein the memory includes non-
`volatile memory.
`
`55. As discussed above, Kato discloses all of the elements of Claim 28. Kato
`
`also inherently discloses the additional limitation of Claim 29. For example, Kato
`
`discloses that a “three-dimensional map is stored in the controller 24 ahead of
`
`time.” Kato at ¶ 31. Kato also discloses the use of a “built-in program.” Id. at ¶
`
`17. A memory that stores a three-dimensional map and a program must
`
`necessarily be non-volatile so that the stored data is not lost when the power is off.
`
`20
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`

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`16. Claim 30
`Limitation: The automatic directional control system
`defined in claim 28, wherein the memory is configured to
`store a predetermined reference position associated with
`the headlight.
`
`56. As discussed above, Kato discloses all of the elements of Claim 28. Kato
`
`also discloses the additional limitation of Claim 30. For example, Kato discloses
`
`that a “three-dimensional map is stored in the controller 24 ahead of time.” Kato at
`
`¶ 31. This map is “predetermi